T.C. Memo. 2002-106
UNITED STATES TAX COURT
SUSAN P. OBERSTELLER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7693-01L. Filed April 29, 2002.
Susan P. Obersteller, pro se.
T. Richard Sealy III and Catherine Tyson, for respondent.
MEMORANDUM OPINION
SWIFT, Judge: This matter is before us on respondent’s
motion under Rule 121 for summary judgment.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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